Introduction

Kakao Corporation (“the Company”) operates the Kakao Code of Business Conduct and the Code of Ethics, and these are used as a guideline in making decisions on ethics-related matters. The Company ensures that all actions taken by the Company, its internal relations and its relationship with outside parties will be based on strict integrity. The standards in this Code are based on laws and regulations which apply to all, and in some case go beyond legal obligations. As such, this Code suggests principles that we must follow to prevent us from violating the values pursued by the Company or from avoiding situations where we seem to violate such values. The standards in this Code may be explained or executed additionally in the policy guidelines or other manuals, and there may be guidelines or manuals related to specific business areas of the Company.This Code of Ethics and related guidelines and manuals can be obtained through the Ethics Department or Agit.

Chapter 1 General Provisions

1. [Purpose]

This Code aims to suggest principles that we must follow to prevent us from violating values pursued by the Company or from avoiding situations where we seem to violate such values.

2. [Scope]

This Code applies to the Company (including domestic and overseas investment companies with management rights) and the Krew. It is also recommended that the Company help its Business Partners to understand and practice them.

3. [Definition]

For purposes of this Code, the following terms are defined as follows.

The level accepted by social conventionsIt is a level which can be accepted by most people with sound common sense, and does not interfere with performing duties in a fair manner.

Interested PartiesAll parties who have an interest in the Company including competitors, suppliers and stockholders. In a broader definition, consumers, employers, the local community, media and civic groups are also included.

Tangible and Intangible AssetsThey include any form of the Company’s finance as well as machinery & equipment, supplies, tools, inventory, funds, computer systems and equipment, computer software, computer data, vehicles, records or reports, confidential information and communication using phones, voice mail or email.

Business Partner (BP)BP refers to a company or organization and members belonging thereto which has or wishes to have transactions or a business relationship with the Company. They are regarded as Business Partners even if they are personally related to the Company (friends, relatives, etc).

Public Servants, etc.Public servants or persons engaging in public duties defined in the Improper Solicitation and Graft Act and persons who are prohibited from engaging in improper solicitation and receiving money, goods, etc. specified in the same Act.

Ethics DepartmentA department responsible for the ethics management of the Company including the management of the Code of Ethics.

Chapter 2 Attitude of the Krew

4. [Sincere Duty Performance]

The Krew understands his or her authorities and responsibilities clearly and perform duties sincerely based on the principle of honesty and trust. In particular, the Krew does not perform a duty unrelated to his or her role.

5. [Holding Multiple Positions]

The Krew and Board members do not work for a competitor, a customer, a distributor or a supplier, or receive a payment for a service from any of them, without the approval of the Ethics Department.

A Krew member must obtain the approval of the Board of Directors if he or she wants to work for a government office or another company. In particular, a majority vote of the Board of Directors is required in the case that a Board member intends to perform any of the following acts.

① Work as a director or a partner with limited liability for a company which is in the same business area as the Company is.

② Enter into a deal in the same business area as the Company under the director’s name or a third party’s name.

③ Enter into a deal with the Company under the director’s name or a third party’s name.

Even though the approval of the Board of Directors is obtained as specified in paragraph ②, the Krew and Board members take appropriate actions to clarify whether the concerned multiple positions are related to the Company’s work or not.

Concerning the “appropriate actions” mentioned in Paragraph ③, the Ethics Department may conduct an audit and make a demand to correct non-compliance.

6. [Maintaining Integrity]

The Krew does its best to fulfill his or her responsibilities and obligations as the member of the society, keeping in mind that their words and actions are directly related to the reliability and reputation of the Company.

7. [Protection of the Company’s Assets and Information]

The Krew allocates and uses the Company’s tangible and intangible assets appropriately.

① The Krew protects the Company’s assets from being destroyed by any loss, damage, misuse, theft or slowdown.

② The Krew ensures that the Company’s assets are used effectively.

③ The Company’s assets are to be used for business purposes only. The approval of management is required if any of the Company’ asset or service is to be used for non-business purposes.

The Company and the Krew must reflect accurately and fairly the transactions and disposal of Company assets in reasonably detail in accordance with laws related to accurate books and records. In particular, the following requirements must be strictly respected.

① A false entry or an entry which may cause misunderstanding is strictly prohibited, and the Company does not allow undisclosed assets and debts for any purpose.

② Payments must be made solely for the purpose recorded in supporting documents.

③ The Krew must perform management and accounting-related control to ensure the accuracy and fairness of all financial statements and other reports.

The Krew must fully cooperate with internal auditors and independent auditors.

The Krew must protect and manage the Company’s information and business secrets, and comply with the Company’s security standards. This obligation remains effective even after they leave the Company, and in particular the following acts are strictly prohibited.

The Krew shall not commit any act which hinders the formation of a healthy relationship between a superior and a subordinate or among colleagues such as sexual harassment and coercion of an act imposing a personal burden. The Krew shall create a sound company atmosphere by recognizing them as mutual partners and treating them respectably. In addition, the following acts are strictly prohibited in order to create a sound corporate culture.

(Act of violence) Physical violence (including a threatening act)

(Abusive language) Violent language

(Sexual harassment) An act which causes sexual humiliation to another person.

(Discrimination) Unjust remarks or acts which despise another person.

(Cover-up) Telling or putting false information in a document to cover up the truth from colleagues in the Company.

9. [Fair Duty Performance]

The Krew shall draw a clear line between official and private matters and perform their duties in a fair and transparent manner when dealing with a BP.

The Krew shall give fair business opportunities to all BPs and dealers, and shall not use their dominant position to make claims or perform an act that will harm fair trade.

The Krew shall not exercise personal influence in the process of supervising and reviewing their performance evaluation or pay rates, or those of close relatives.

10. [Conflict of Interest]

The Krew shall not act against the Company’s interest or create a situation of conflict of interest regarding the Company’s legitimate business attempt.

The following acts are prohibited in the case that the Krew may exercise an influence, or it is deemed that the Krew’s judgment or action could be affected. Provided however that strict judgment and application is needed in real situations because all cases of conflict of interest are not listed here.

① Where the Krew makes a business deal with the Company, a BP or a competitor directly or through a third party;

② Where the Krew engages in loans, joint investment, loan guarantee, or lease of real estate or movable assets with a BP directly or through a third party;

③ Where the Krew receives a compensation from a BP directly or through a third party; and

④ Where the Krew holds the BP’s stocks or bonds directly or through a third party. (Exceptions apply if it has been approved by the Company.)

The Krew is prohibited from gaining illegal profits directly or through a third party using information obtained in the course of duty performance, including the following.

① The Krew purchases, directly or through a third party, any asset or securities which the Company intends to purchase or lease.

② The Krew receives a guarantee from a BP on the employment of or hiring recommendation for himself/herself or a third party using a private advice opportunity based on the Company’s information.

The Krew shall report to the Ethics Department any transaction between its family/relatives and the Company or a BP because it may cause a conflict of interest.

11. [Gifts and Entertainment]

The Krew shall not receive any gifts and entertainment from other parties including interested parties. If a Krew member receives a gift or entertainment in an unavoidable circumstance, he or she shall take the following actions, report to a supervisor, and inform the result to the Ethics Department.

① Returnable gifts must be returned immediately.

② If a gift cannot be returned, the Krew member shall makes an inquiry to the Ethics Department and take care of it based on the Department’s advice.

Receiving gifts or entertainment is acceptable in the following cases as an exception. However, its price or value should be of the level accepted by social conventions. You are to make an inquiry to the Ethics Department if you have difficulty making a decision.

① Promotional material or event souvenirs

② Money given on happy and sad occasions

③ Simple refreshment

The Krew shall not provide gifts or entertainment to other parties including interested parties. In particular, they are prohibited from engaging in improper solicitation and providing gifts and entertainment to public servants, etc. by violating the Improper Solicitation and Graft Act.

The Krew shall not request any gift, money for happy and sad occasions, other rewards or preferential treatment to interested parties for the benefit of their family or friends.

If they receive a meeting allowance for attending a meeting organized by the government or a government agency as a representative of the Company, it must be reported to the Ethics Department.

The Krew must report to the head of his or her department any work-related contact with a BP outside the office hours.

12. [Compliance with the Code of Ethics]

The Krew is obligated to comply with this Code and take an oath to comply with it. If there is a question regarding its interpretation and application, it must be discussed with the head of the Ethics Department.

The Krew shall report to the head of the Ethics Department when recognizing a violation of the Code of Ethics.

The head of each department is responsible for actively supporting and managing BPs related to the Company’s work so that they can understand and comply with the Code of Ethics.

The Krew shall sign a pledge to practice ethical management and comply with the pledge on a yearly basis.

Violation of this Code will be handled according to the Company regulations.

Chapter 3 Responsibility Towards Customers

13. [Customer-Oriented Management]

The Company provides products and services which can satisfy its customers through such means as the adoption of an advance test process to enhance product integrity during product development.

The Company does its best to clarify the needs of customers, actively accommodates the customers’ reasonable demands and suggestions, and keeps its promise to the customers.

The company provides timely information to help customers choose products and services reasonably.

14. [Consumer Information Protection]

The Company complies with laws and regulations related to customer information, continues monitoring and improving its work process for customer information protection, and if necessary operates a pre-impact assessment system for customer information during the product development phase.

The Company does its best to protect customer information, including the implementation of the optimal IT security system and the operation of a specialized customer information manager.

The Company does not use customer information for purposes other than for which they has been provided, or provide them to any third party, without obtaining prior consent of customers or otherwise permitted by law.

15. [Enhancement of Customer Value]

In providing products and services to its customers, the Company is committed to enhance the customers’ value by maintaining the product quality meeting customers’ expectation, creating an environment where customers can use the products and services safely and beneficially, etc.

Chapter 4 Responsibility Towards the Krew

16. [Human-Oriented Management]

The Company provides a work environment free from discrimination against ethnicity, gender, ideology, religion, age, disability or sexual orientation.

The Company respects the Krew’s personality, and treats them reasonably based on their competence and performance.

The Company supports each Krew member to achieve his or her goals by providing an optimal work environment, etc.

The Company supports the Krew’s self-development activities and actively provides training opportunities related to their work.

17. [Safety and Happiness of the Krew]

The Company complies with relevant international standards, laws, and internal rules by arranging a system to ensure the Krew’s safety and happiness, and conducting relevant training on a regular basis.

The Company is committed to help the Krew have mutual trust and pride, show challenging spirit and creativity, and pursue happiness with co-workers.

Chapter 5 Responsibility Towards Stockholders

18. [Enhancement of Corporate Value]

The Company maximized the corporate value based on transparent and efficient management through constant innovation, and shares the result with stockholders.

19. [Protection of Shareholders’ Interests]

The Company exercises a transparent management centered on the Board of Directors, and respects reasonable demands and suggestions of its stockholders.

The Company prepares its disclosure information including financial statements in accordance with relevant laws and accounting standards, and discloses them properly, accurately, completely and timely according to relevant laws and regulations.

Chapter 6 Relationship with Business Partners

20. [Sustainable Management]

The Company selects a BP which satisfies the business purpose based on fair and reasonable standards, evaluates the BP on the delivery process, quality, etc using the same standards, and informs the result to the BP through appropriate means.

The Company does not use its dominant position to commit illegitimate acts, and pursues mutual interests and co-development.

The Company recognizes BPs as strategic partners who pursue a common value of customers’ happiness based on mutual trust.

21. [Protection of BP’s Information]

The Company protects any BP’s information and business secrets, and does not use BP’s information for purposes other than for which they has been provided without obtaining a prior consent or otherwise permitted by law.

The Company does not obtain or use the information or business secret of another party including BPs.

Chapter 7 Responsibility Towards the Society

22. [Compliance with Laws, Rules and Regulations]

It is the Company’s policy to be a good “corporate citizen”. The Krew shall comply with laws, rules and regulations mentioned below.

Laws, regulations and rules of the country where the Company operates its business.

Conditions of business agreements

Other customs and standards deemed to be ethical by the social convention in regions where the Company operates its business.

23. [Restriction of Competition]

The Company complies with the laws related to restriction of competition of a country where the country where the Company operates its business.

The Company and the Krew shall not engage in collusion including the signing of a contract which restricts competition with another party unreasonably.

The Krew shall not discuss sensitive information related to competition including pricing, contract terms and other confidential information.

24. [Promotion of a Sound Culture]

The Company improves the quality of human life by creating a convenient and abundant society through constant technological innovation, business advancement, etc, and thereby contributing to the happiness of mankind.

The Company does its best to create and promote a sound culture in the local community when running its business by considering whether its service is harmful socially or culturally.

25. [Respect for Human Dignity]

The Company does not discriminate any interested party including customers, employees or executives in the area where it operates its business due to race, religion, gender, disability, etc.

The Company protects basic human rights in the area where it operates its business such as minor rights and customer privacy.

26. [Environmental Friendly Management]

The Company complies with international standards, laws, and internal rules related to environmental protection, and practices environmentally-friendly management.

27. [Social Contribution]

The Company actively participates in social volunteer activities such as volunteer programs and disaster relief as a corporate member of the in the area where it operates its business.

28. [Political Neutrality]

While the Company respects individual political rights and expression of political opinions, it does not allow any personal political activity using the Company’s funds, manpower or facilities for political purposes.

The Krew is prohibited from making any political donation on behalf of the Company without the CEO’s approval.

The Company avoids inappropriate transactions with the government and complies with relevant laws in all countries.

Chapter 8 Reporting and Informant Protection

29. [Reporting and Informant Protection]

The Ethics Department may establish and operate a hot line in the company system to make inquiries on ethical matters.

Upon receiving an inquiry or a report related to ethical management, the head of the Ethics Department follows up with additional fact-checking after obtaining an approval from the permanent Ethics Committee and take the following actions if necessary.

① The report or inquiry is transferred to a concerned department or addressed based on coordination between the head of the Ethics department and the concerned department.

② A deliberation of the permanent Ethics Committee may be requested if it is deemed that the report or inquiry requires a disciplinary review.

The Company takes the following actions for reports and inquiries related to BPs.

① The Company may decide on a favorable arrangement for the BP and the informant after receiving a pledge to prevent the recurrence of the same issue depending on the severity of the issue and level of violation.

② Notwithstanding the above Item, the Company may take necessary measures such as restriction of transaction volumes for the BP or contract termination depending on the severity of the issue and its impact on the Company and the society.

The Company does its best to protect the informant and encourage inquiries and reports.

① The Company protects the identity and details of the inquiry or report, and does its best to prevent any disadvantage resulting from the inquiry or report.

② If the informant believes that his or her identity has been disclosed and therefore needs protection, he or she may report the fact to the head of the Ethics Department and request for identity protection. In this case, the head of the Ethics Department may take necessary actions such as legal support or transfer to another department through coordination with the head of the concerned department.

③ The Krew shall not ask the Ethics Department about the identity of an informant, and take any action to expose the informant’s identity including questioning and an act of revenge. Such actions may be subject to a disciplinary review.

④ If the informant is involved in misconduct but reports the fact to the Company, the Company may consider the extenuating circumstances when determining a disciplinary action or punishment.

⑤ The Company may reward an informant who has contributed to the good of the Company by making an inquiry or report.

The head of the Ethics Department keeps a record of inquiries and reports related to the Code of Ethics and the results in the order of report/inquiry date.